Date:    09/25/2000  11:11 AM

Subject: File No. S7-13-00

Dear Chairman Arthur Levitt, Commissioners Paul Casey, Isaac Hunt and Laura 
Unger:
     
I am a CPA practicing in a local CPA firm in Conshohocken, Pennsylvania (a 
suburb about 15 miles from center city
Philadelphia).  I am writing to voice my concerns regarding the recently 
proposed SEC rule S7-13-00 that could
prohibit auditors from rendering non-audit services to their audit clients. 
We have one SEC account,  are members
of the AICPA SEC Division of Firms, but primarily perform compilations and 
reviews and render computer consultation
regarding a software product (Macola).  The computer consulting is performed 
exclusively by one member of our firm
who does no accounting work and exclusively devotes his time and expertise 
to the computer consulting area.
     
We believe that the proposal would limit the services that we presently 
perform, although the computer consulting
services rendered to the SEC client are mainly technical in nature and have 
no influence on the manner in which they
maintain their accounting records.  The SEC client is not a user of Macola 
but we have assisted them in obtaining
equipment and other software and have installed or implemented this on their 
systems.  Their business is such that
Macola could be an appropriate system for them to use and, should they make 
such a decision, would probably want
us to provide the software and implementation for them.  We have also aided 
them when they encounter problems with
their equipment or network in order to get them running efficiently.
     
We do not believe that our fact situation raises any independence issue and 
we are unaware of any fact situations that
have specifically triggered the SEC decision to implement this rule.  We 
agree with the Public Oversight Board that
instances such as ours contribute to greater efficiencies of the client and 
have a positive effect on the audit.  It appears
that this conclusion has been overlooked by the SEC in making this proposal.
     
We have noted that rules set by the SEC usually set the standard for the 
industry and are adopted by other regulators.
Our firm serves many small businesses and this ruling could be crippling to 
both our practice as well as the clients
we serve.  Many are closely held, family businesses without the resources to 
hire sophisticated accounting personnel.
We are relied on to be their business advisors, tax and estate planners and 
to aid them in many other areas.  We have
a substantial knowledge of their businesses and are available to advise them 
when they contemplate transactions or
need guidance.  If this ruling were to force them to choose whether to have 
us as their auditors or their advisors, they
would require two sets of accountants which would be more costly and 
probably not achieve the same degree of
professionalism or results.
     
There are already standards in place that are monitored by the AICPA, the 
state accounting societies and other accounting
regulatory boards and committees that govern the independence issues that 
the SEC is now rehashing.  We believe that
the SEC's proposal to restrict services offered by firms such as ours 
undermines these regulatory boards and is an
attempt to restructure our profession that, as a whole, has provided the 
public with reliable, independent data for many
years.
     
We believe that the proposed ruling, as written, should not be passed.
     
Thank you for your consideration of our comments.
     
Very truly yours,
     
Steven M. Mayer, MT, CPA
Mayer, Shanzer & Mayer, P. C.
20 East Eleventh Avenue
Conshohocken, PA  19428-1555

Copy by fax:  Rep. Joseph Hoeffel III